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CIRS Successfully Assists Client in Obtaining A Türkiye KKDIK Individual Temporary Registration Number

from CIRS by

In March 2026, the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) issued a major announcement officially launching the "Individual Temporary Registration" pathway. Enterprises no longer need to wait for a Lead Registrant (LR), purchase a Letter of Access (LOA), or be restricted by tonnage bands. They can directly submit a separate temporary registration to quickly obtain a registration number. With the temporary registration deadline set for September 30, 2026, any substance lacking a temporary or full registration number after this date will be barred from the Turkish market.

As a professional service provider, CIRS Group has successfully assisted a client in obtaining a KKDIK individual temporary registration number (an 18-digit number starting with "98"). Having successfully navigated the complete process under the updated framework, we empower enterprises to stay ahead of the curve in Turkish market compliance.

Core Breakthroughs: Eliminating LR Dependency via Individual Temporary Registration

Individual Temporary Registration is a statutory, independent registration pathway applicable to all scenarios, regardless of joint submission status. It comprehensively resolves registration bottlenecks with the following regulations:

No Joint Submission Restrictions: Enterprises can opt for an individual temporary registration regardless of the joint submission status. Individual Temporary Registration is not restricted by whether a Lead Registrant (LR) exists, has initiated their own registration, completed their dossier, or published the Letter of Access (LOA) pricing.

No Tonnage Band Limitations: The Individual Temporary Registration universally applies to all substances requiring registration under KKDIK. Companies can complete their temporary registration via individual submission irrespective of their specific tonnage band.

Individual temporary registration is an official, regulation-backed compliance route. Upon submission, an independent registration number starting with "98" is generated, which shares the exact same market access rights as a joint registration. Please note that all pre-registration numbers will expire on September 30, 2026, by which time a temporary or full registration number must be secured.

Practical Experience: Registration Timeline and Required Dossiers

Registration Timeline: It typically takes four to six weeks from initial document preparation to securing your registration number, depending on the following process:

Step 1 – Pre-registration Status Confirmation: Verifying if pre-registration has been completed.

Step 2 - Dossier Preparation (1-2 weeks): Gathering substance information, tonnage, and importer details to prepare the registration dossier.

Step 3 - KKS Submission and Official Review (2-4 weeks): Entering data into the system and payment of administrative fees.

Step 4 - Obtaining the Temporary Registration Number: Available for customs clearance and SDS updating.

* Required Document Checklist: According to the latest regulatory requirements, individual temporary registration requires the following core information:

Type of Information

Required?

Description

Substance Identification (such as Name, and CAS No.)

✅ Yes

Required for all registrants.

Importer Information

✅ Yes

Includes details of both the registrant and the Turkish importer.

POA

✅ Yes

Applicable to non-Turkish enterprises appointing an Only Representative (OR).

Analytical information

⚠️ Exemptible

Requires reasonable justification for exemption; to be supplemented during the full registration.

Tonnage band

✅ Yes

Registration tonnage and tonnage information for the previous three years.

Identified uses

✅ Yes

 

Physicochemical Data (P&C)

⚠️ Exemptible

Requires reasonable justification for exemption; to be supplemented during the full registration.

SDS

✅ Yes

Turkish version preferred; English version is acceptable if unavailable.

Obligations After Obtaining the Registration Number

Tonnage Tracking: The OR must track the actual import tonnage to ensure compliance.

Importer Information Filing: If there are changes to importers, the information must be promptly updated in the KKS system.

SDS Compliance Update: The SDS must be compiled in accordance with KKDIK Annex II, clearly indicating the registration number and the Chemical Assessment Expert (CAE) information.

Dossier Maintenance: Any information changes must be updated within three months; extensions can be requested if necessary.

Full Registration Obligation: Information exempted during temporary registration must be supplemented during the full registration. A maximum extension of two years can be applied for.

Recommendations

According to the latest MoEUCC announcement, September 30, 2026, is the ultimate deadline for all enterprises manufacturing, importing, or using chemical substances in Türkiye to obtain a registration number. After this date, all previously issued pre-registration numbers will automatically expire, and the Turkish customs system will fully implement a real-time verification mechanism for KKDIK registration numbers. Substances without a valid registration will be blocked from customs clearance and prohibited from sale.

Based on official forecasts, nearly 100,000 registration dossiers are expected to be submitted in a concentrated burst around the deadline. The KKS registration system will face significant access pressure, drastically increasing the risk of system delays and extended review cycles (the current average review time has already increased by 30–50% compared to normal).

CIRS Group strongly advises enterprises to initiate the following steps immediately:

Immediate Verification: Confirm whether your substances have a valid pre-registration and evaluate if their pre-registration status remains active.

Strategic Decision-Making: Carefully evaluate whether Individual Temporary Registration is applicable based on substance tonnage, supply chain stability, and commercial planning.

Prompt Action: Contact a consultancy with OR capability, such as CIRS Group, immediately to consult a compliance advisor and reserve slots for technical dossier preparation and submission. The earlier you start, the more likely you are to avoid the submission peak, ensuring successful registration and a controllable timeline.

CIRS Group has been deeply engaged in global chemical regulatory services for nearly 20 years, assisting thousands of Chinese and overseas enterprises in completing pre-registrations and registrations under chemical frameworks such as Türkiye's KKDIK.

Our Services

  • KKDIK Regulation Compliance Consulting & Training
  • KKDIK OR Service
  • KKDIK Pre-registration & Temporary Registration Services
  • KKDIK Full Registration Service
  • Türkiye CLP (SEA) Regulation Compliance Consulting & Training
  • Türkiye CLP (SEA) Regulation OR Service
  • C&L Notification under Türkiye CLP (SEA) Regulation
  • Türkiye SDS & Label Preparation

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

Why 2026 Is Now the Only Deadline That Matters for Turkey REACH (KKDIK) Compliance

  

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